Privacy Policy

Contents

1. Important information and who we are

2. The data we collect about you

3. How is your personal data collected?

4. How we use your personal data

5. Disclosures of your personal data

6. International transfers

7. Data security

8. Data retention

9. Your legal rights

Introduction

Welcome to the Spirehouse Recruitment Limited privacy policy.

Spirehouse Recruitment Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

1. Important information and who we are

We are a recruitment business specialising in temporary and permanent recruitment services. We collect the personal data of the following types of people to allow us to undertake our business:

Prospective and placed candidates for permanent, contract, fixed term, interim and part-time roles
Prospective and live client contacts
Supplier contacts to support our services
Employees, consultants, part-time workers

Purpose of this privacy policy:

This privacy policy aims to give you information on how Spirehouse Recruitment Limited collects and processes your personal data.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller:

Spirehouse Recruitment Limited is the controller and responsible for your personal data (collectively referred to as Spirehouse Recruitment Limited, "we", "us" or "our" in this privacy policy).

If you have any questions about this privacy policy, please contact us using the details set out below.

Contact Details:

Full name of legal entity: Spirehouse Recruitment Limited

Email address: dataprotection@spirehouse.co.uk

Registered address: 109 Sarehole Road, Hall Green, B28 8ED

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes:

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. The data we collect about you

Candidates and Contractors:

All of the information we collect is necessary to be able to find available job opportunities, and check your eligibility for work. This information may be used at several stages of the recruitment process, from first introduction, through screening, assessment and interviews, to final appointment.

The following information will normally include:

Name
Contact telephone number(s)
Email address
DOB
Curriculum Vitae
Proof of identity (residential address, national insurance number, passport etc.)
Employment references and their contact details
Bank details (to ensure payment can be made)
Proof of eligibility to work in the UK.
Next of kin details

In some circumstances we may also need to collect sensitive data, such as personal medical information, immigration records or criminal conviction records. We only collect and hold this after you have given us your explicit consent to do so.

Clients:

We collect contact details normally including:

Name
Job title
Telephone numbers
Email address

This is to enable us to tell you about potential workers we have that could suit your organisation. Our contracts typically hold contact details of principal parties to the contract.

Suppliers:

We collect your contact details such as your names, job titles, telephone numbers and email addresses to enable us to contact you to contract with you for the services you are providing. We also hold your financial information to enable us to pay you.

3. How is your personal data collected?

We use different methods to collect data from and about you including through (please not this list is not exhaustive):

You, directly: This could be via a CV, registration form or job application
An agent/third party acting on your behalf. e.g., Contractors Limited Company.
Sources where you have yourself made the data publicly available. such as:
LinkedIn
Online job boards (it is our policy to advise you of the source when we first communicate with you)
Marketing databases
Social media
Spirehouse Recruitment Limited website
A reference or word of mouth. For example, you may be recommended to us by a friend, a former or present employer or colleague.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Assess your skills, qualifications, and suitability for the role
Carry out reference checks
Communicate with you about the recruitment process
Keep records related to our hiring process
Comply with legal or regulatory requirements
Engage you for a role with us or with our Clients including any related administration to include timesheets and payroll
Carrying out reasonable welfare checks
Communicating with third parties in the event of an emergency, accident or any issue relating to workplace safety
Collating market or sector specific information and providing the same to our Clients
Sending information to third parties with whom we have or intend to enter into arrangements which are related to our Recruitment Services
Complying with our own legal obligations, for example reviewing, using and passing on information as required for the protection of health and safety of staff and visitors
Providing information to regulatory authorities or statutory bodies, and our legal or other professional advisers including insurers
To market our Recruitment Services
Retaining a record of our dealings
Recording how you engage with our Recruitment Services including through our website and IT and communication systems
Establishing quality, training and compliance with our obligations and best practice
or the purposes of backing up information on our IT and communications systems

Our legal basis for the processing of personal data is for our legitimate business interests, described in more detail below:

As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment, fixed term contract placements, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.

In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.

If you are interviewed and submitted as a candidate, this may involve the processing of more detailed personal data including sensitive data such as health information that you or others provide about you. We always ask for your consent before undertaking such processing.

To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts. You have the right to withdraw consent to marketing at any time by contacting us.

5. Disclosures of your personal data

We may share your personal data with the parties set out below:

Candidates and other third parties necessary for the provision of our Recruitment Services
Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us
Parties who process data on our behalf, which may include
Outsourced payroll providers
IT support
Storage service providers including cloud providers
Background screening providers
Legal and professional advisers
Insurers
Our staff
Emergency services and health professionals in the event of an emergency, accident, injury or a risk to the health and safety of you or others

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We do not transfer personal data outside of the EEA.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Candidate data:

Up to 2 years from our last meaningful contact with you
For 7 years from the end of the tax year to confirm relevant Income Tax, pension and VAT records against payroll

Contractor data:

7 years from the end of each tax year, as required by law governing the retention of payroll and VAT records

In some circumstances we are required by law to retain your data for longer than a 7 year period. These circumstances include legal or contractual aspects of certain specific roles (such as regulator registered Senior Managers in financial firms), or where your experience includes a significant specialist skill set which may remain in demand for a longer period of time.

Client contact details:

So that we remain able to provide you with contract and interim employees, your contact details will be retained for the period of 7 years since the last meaningful contact with you.

More detailed information on retention periods for different categories of data is identified in our Data Retention Policy, available on request.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data's accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.